These Environmental Advertising Terms Become Risky from 2026

With the EmpCo Directive (EU) 2024/825, the way businesses may talk about environmental benefits is changing. In Germany the rules transposed via the Third UWG Amendment Act (BGBl. 2026 I No. 43) apply from 27 September 2026. One point up front: there is no official "banned list" of individual words. What matters is context – whether a claim is specific, verifiable and correctly framed. Even so, typical terms can be grouped by risk level to help set priorities.

Which terms count as particularly risky (per se critical)?

The most critical are generic neutrality claims that essentially rely on offsetting. They sit at the centre of the new rules and should be reviewed as a priority:

• "climate neutral"
• "CO₂ neutral"
• "climate positive"
• "produced 100% climate neutral"
• "environmentally neutral"

These claims suggest an overall effect that often results only from a calculated offsetting of emissions. Where such offsetting is the load-bearing basis, the claim is considered particularly risky. It is safer to name the concrete contribution – such as a verifiable emission reduction at source – rather than asserting a blanket neutrality claim.

This group also includes sustainability labels without a recognised basis, especially self-designed labels that have not undergone an independent certification step.

Which terms require substantiation (generic terms)?

The second group consists of general environmental terms. They are not automatically impermissible but require solid evidence of a recognised, excellent environmental performance. Without proof they are considered risky:

• "sustainable"
• "environmentally friendly"
• "eco" / "ecological"
• "green"
• "resource-saving"
• "close to nature"
• "conscious" / "responsible" (in an environmental context)

The problem with these terms is their vagueness: they leave open what the benefit relates to and how large it is. A mere assertion is not enough. Anyone wishing to use such terms should tie them to a specific, verifiable statement – for example a particular material property, a process, or a measurable metric with a clear reference point.

Which terms are context-dependent?

The third group comprises terms that can be permissible or risky depending on how they are used. Here the reference point decides:

• "recycled" / "recyclable"
• "biodegradable" / "compostable"
• "plastic-free"
• "made from renewable raw materials"
• "energy efficient"
• "regional" (with an environmental angle)

Such statements are more likely to hold up where it is clear what they refer to and how large the share or effect is. "Recycled", for instance, raises the question: which share of material, relating to which component? "Biodegradable" depends on the conditions under which degradation actually takes place. If the reference point is missing or the statement is generic, the risk rises significantly.

Why is context more important than the individual word?

The EmpCo logic does not target individual vocabulary but misleading overall impressions. Even a generally permissible term can become risky if:

• it refers to the whole product although only one aspect is concerned;
• imagery (green colours, leaves, globes) creates a broader impression;
• it implies a comparison without disclosing method and reference point;
• it promises future environmental performance without a verifiable implementation plan.

Conversely, even a vague term can remain permissible if it is directly tied to a concrete, substantiated benefit. That is why no word list replaces an assessment of the individual case.

How do I handle risky terms in practice?

A pragmatic path is classification by risk and step-by-step remediation. Replace generic neutrality claims as a priority, back generic terms with evidence, and make context-dependent statements more precise with a clear reference point. A structured guide is offered by the empco-checkliste; the wider legal framework is explained in green-claims-directive-2026.

For context: this article names typical risk areas but does not replace an individual legal review. Whether a specific claim holds up depends on context, the available evidence and – for cross-border advertising – the respective national implementation.

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